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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. 01-15-00541-CV
Regular Panel Decision
Aug 31, 2015

Alborz Datar v. National Oilwell Varco, L.P.

This is a failure to accommodate and wrongful termination case under Chapter 21 of the Texas Labor Code and the Texas Workers’ Compensation Act. Datar worked for NOV for five years, most of that time as a welder. Datar did not have any poor performance evaluations, warnings, or write-ups. In fact he was praised and given a raise in February 2013. Only a few months later, in May 2013, Datar was injured at work, accordingly obtained workers’ compensation benefits, and sought disability-related accommodations. Also, that same month, he made a complaint of sexual harassment, which was acknowledged and investigated by NOV. NOV refused any accommodations and fired him on June 3, 2013, one business day after it completed its investigation into his harassment complaint and literally minutes after he returned from getting an MRI related to his workplace injury. During the termination meeting Datar indicated his ongoing willingness to work, and his immediate supervisor later admitted that he could have continued working rather than be terminated. Furthermore, NOV did not follow its company-wide progressive discipline policy, as it has with other similarly situated employees. As a result, the district court erred in granting summary judgment, as there are fact issues that a jury should resolve.

Disability DiscriminationTCHRA RetaliationWorkers' Compensation RetaliationSexual Harassment ComplaintSummary Judgment AppealEmployment LawsuitProgressive Discipline PolicyWrongful TerminationFailure to AccommodateAppellate Brief
References
32
Case No. MISSING
Regular Panel Decision

Cornyn v. Speiser, Krause, Madole, Mendelsohn & Jackson

Appellants, former Southwest Airlines ticketing agents, sued their former attorneys for legal malpractice and Southwest Airlines for an unsafe workplace, alleging discrimination under the Americans with Disabilities Act (ADA) and Texas Health and Rehabilitation Act (TCHRA) due to work-related injuries. They claimed their attorneys failed to timely file an ADA lawsuit and that Southwest failed to provide reasonable accommodations. The trial court granted summary judgment for the defendants. The appellate court affirmed, holding that the appellants were estopped from claiming they could work with accommodations because they had applied for and received workers' compensation and disability benefits, consistently asserting they were unable to work.

Legal MalpracticeUnsafe WorkplaceSummary JudgmentAmericans with Disabilities Act (ADA)Texas Commission on Human Rights Act (TCHRA)Disability BenefitsWorkers' CompensationEstoppel DoctrineElection of RemediesQualified Individual with Disability
References
19
Case No. MISSING
Regular Panel Decision

Pedroza v. Autozone, Inc.

Rogelio Pedroza, an Autozone employee, sued Autozone for disability discrimination under the Americans with Disabilities Act (ADA) after being terminated. Pedroza suffered two workplace injuries, leading to physical restrictions. He alleged Autozone failed to provide reasonable accommodations and discriminated against him based on his disability. Autozone moved for summary judgment, arguing Pedroza was not a 'qualified individual with a disability' under the ADA and that his termination was due to a neutral attendance policy. The Court granted Autozone's motion, finding that Pedroza's physical limitations did not substantially limit a major life activity (except for sexual activity, where a fact issue existed, but this was not enough for the overall claim) and that he failed to demonstrate he was a 'qualified individual' able to perform essential job functions, with or without reasonable accommodation. Furthermore, Pedroza could not prove Autozone's reason for termination (exceeding a one-year leave of absence limit) was a pretext for discrimination.

Disability DiscriminationAmericans with Disabilities Act (ADA)Summary JudgmentWorkplace InjuryReasonable AccommodationEssential Job FunctionsPrima Facie CasePretext for DiscriminationAttendance PolicyFifth Circuit Precedent
References
65
Case No. MISSING
Regular Panel Decision

Guerrero Toro v. Northstar Demolition

Plaintiff Alexander Guerrero Toro, a pro se asbestos handler, sued NorthStar Demolition & Remediation LP under the Americans with Disabilities Act (ADA) and New York State Human Rights Law (NYSHRL), alleging failure to accommodate his carpal tunnel syndrome, wrongful termination, workplace harassment, and retaliation. After experiencing pain in his right arm, Plaintiff was placed on restricted duty, limiting his ability to perform essential job functions. Defendant provided various temporary light-duty assignments, but eventually, no suitable tasks remained due to seasonal changes and Plaintiff's ongoing limitations. Plaintiff also claimed harassment from co-workers and supervisors, and retaliation for filing administrative complaints. The court granted Defendant's motion for summary judgment, dismissing all claims, concluding that Plaintiff failed to demonstrate he could perform essential job functions with or without reasonable accommodation, or that a hostile work environment or retaliation existed based on admissible evidence. The NYSHRL claims were also dismissed, with some being jurisdictionally barred due to the election of remedies.

Americans with Disabilities ActDisability DiscriminationCarpal Tunnel SyndromeReasonable AccommodationHostile Work EnvironmentRetaliationSummary JudgmentPro Se LitigationEmployment LawNew York State Human Rights Law
References
122
Case No. MISSING
Regular Panel Decision

Maliqi v. 17 East 89th Street Tenants, Inc.

The court addresses motions in limine concerning the admissibility of evidence related to the plaintiff's immigration status, future lost wages, and medical expenses in a workplace injury case. The plaintiff, an undocumented political asylum seeker named Maliqi, was injured while working. The court ruled that while the plaintiff's immigration status is relevant for the jury to consider potential economic realities if he is deported, it cannot be used to argue that his status prohibits awards for future lost wages or medical expenses. Furthermore, the defendant is precluded from asserting that the plaintiff was working illegally at the time of the accident. The court also permitted expert testimony from an economist regarding future damages but denied the admission of testimony from the plaintiff's immigration counsel as an expert.

Workplace InjuryUndocumented WorkerPolitical AsylumImmigration StatusLost WagesMedical ExpensesEvidence AdmissibilityMotions in LimineExpert TestimonyEconomic Damages
References
13
Case No. MISSING
Regular Panel Decision

Bentley v. Peace and Quiet Realty 2 LLC

Daphne Bentley, a 66-year-old disabled woman, sued her landlord for refusing to allow her to move to a vacant lower-level, rent-stabilized apartment at her current rent, alleging a violation of the Fair Housing Act. Bentley, who suffers from cancer and difficulty climbing stairs, sought this accommodation to improve her ability to leave her top-floor apartment. The defendants moved to dismiss, arguing the requested accommodation was not contemplated by the FHAA, contending Bentley sought to accommodate her poverty, not her disability, and that offering the apartment at its maximum legal rent fulfilled their obligations. The court denied the defendants' motion to dismiss, ruling that Bentley's request to transfer units within the building is a cognizable accommodation under the FHAA and that a disability-neutral policy does not automatically preclude an inquiry into the reasonableness of the proposed accommodation. The court scheduled a hearing to determine the reasonableness and potential burden of the requested accommodation.

Disability AccommodationFair Housing ActRent Stabilization LawReasonable AccommodationHousing DiscriminationTenant RightsUndue BurdenMotion to DismissFederal JurisdictionEqual Opportunity
References
19
Case No. 2014-07-0024
Regular Panel Decision
Mar 23, 2015

Ricketts, David v. Dana Holding Corporation

David Ricketts, an employee, filed a Request for Expedited Hearing seeking additional temporary disability benefits after being terminated by Dana Holdings Corporation on September 3, 2014. Ricketts sustained a left shoulder injury on August 4, 2014, for which Dana authorized medical care. His termination resulted from allegations of falsifying company documents and sleeping while clocked in. Ricketts argued his actions were inadvertent and that his termination should not affect his entitlement to benefits. The Workers' Compensation Judge denied the claim, finding that Dana terminated Ricketts for cause and could have accommodated his medical restrictions, thus upholding the employer's right to enforce workplace rules.

Workers' CompensationExpedited HearingTemporary Disability BenefitsTermination for CauseWorkplace PolicyEmployee MisconductModified DutyShoulder InjuryRotator Cuff TendonitisTime Clock Violation
References
7
Case No. 2017-01-0335
Regular Panel Decision
Nov 21, 2017

Laboo, Zachariah v. Koch Foods, LLC

This expedited hearing concerned Zachariah Laboo's request for temporary partial disability benefits after being terminated by Koch Foods, LLC. Mr. Laboo injured his right thumb at work and underwent surgery. While accommodated with restrictions, he accumulated points under Koch's attendance policy, leading to a corrective action notice. Despite Mr. Laboo's differing account of events, the court found that Koch Foods had cause to terminate his employment due to violations of workplace expectations, including attendance issues, insubordination during a meeting, and failure to attend a scheduled meeting. Consequently, the Court denied Mr. Laboo's claim for temporary disability benefits.

Temporary Disability BenefitsTermination for CauseWorkplace MisconductAttendance PolicyInsubordinationUlnar Collateral Ligament InjuryRight Thumb InjuryWorkers' Compensation ClaimsExpedited HearingEmployer Rules
References
3
Case No. MISSING
Regular Panel Decision

Lindloff v. Schenectady International

Plaintiff filed an action under the Americans with Disabilities Act (ADA) after being discharged from his position at Defendant's Lake Jackson, Texas facility. Plaintiff suffered from leukoderma, a skin condition caused by exposure to phenolic compounds in his workplace. Despite initial accommodations, Dr. Peltier eventually recommended Plaintiff completely avoid phenolic compound exposure, leading to his termination. The Court granted Defendant's Motion for Summary Judgment, ruling that Plaintiff's leukoderma did not constitute a disability under the ADA as it did not substantially limit any major life activities. The Court also found no evidence that Defendant regarded Plaintiff as disabled, ultimately dismissing all claims with prejudice.

Americans with Disabilities ActADASummary JudgmentDisability DiscriminationEmployment TerminationLeukodermaPhenolic Compound ExposureWorkplace InjuryFederal CourtFifth Circuit
References
8
Case No. MISSING
Regular Panel Decision
Oct 31, 1996

Guneratne v. St. Mary's Hospital

Plaintiff Barbara Guneratne sued St. Mary's Hospital alleging unlawful discrimination under the ADA and Rehabilitation Act, and retaliation under the Texas Worker’s Compensation Act, following a workplace back injury. Guneratne claimed the hospital refused her return to work despite physician releases, arguing it was discriminatory. The Court granted summary judgment for the defendant, ruling that Guneratne could not perform the essential job functions of a clinical nurse, particularly heavy lifting, and that no reasonable accommodation was feasible. Additionally, the Court found no causal link between her worker’s compensation claim and the hospital's decision, leading to the dismissal of all claims with prejudice.

Americans with Disabilities ActRehabilitation ActTexas Worker's Compensation ActEmployment DiscriminationRetaliatory DischargeSummary JudgmentEssential Job FunctionsReasonable AccommodationWorkplace InjuryNurse
References
10
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